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Title : Pi Litigation Paralegal

Location : Florida - Fort Myers
Refer to Job # OEBU739834

PI Litigation Paralegal The candidate will review files as received that are entering litigation; this review also includes identifying potential defendants to be named in the lawsuit. Request missing documentation, it becomes the responsibility of the paralegal to follow up on receipt of responses. Create to-do for follow up. Review, index, organize, and summarize documents produced by other parties and medical health care providers; when appropriate prepare medical notebook. Obtain, review, and organize damage information; calculate damages (medical expenses, lost wages, household expenses, consortium claims, property damages); prepare, maintain, and update damages summaries. Develop information and acquire records not obtained pre-suit for wrongful death, i.e. supporting evidence regarding sibling and/or child/parent economic claims. Prepare and forward demand packages to insurance carriers or defense attorneys. Meet with client; coordinate the collection and review of client files; gather, organize, summarize, and analyze documentation collected. Draft responses / answer discovery to interrogatories, requests for admissions, requests for production. Draft and serve supplemental discovery directed to the defendant, including expert and/or trial interrogatories, requests for site inspection, nonparty production requests served by plaintiff upon nonparties, and obtain service of nonparty production subpoenas. Prepare and file motion for mediation and notice for trial (if not already done on the file). Prepare affidavits of documents and maintain document files and case correspondence. Conduct research to locate, communicate with, interview, and retain expert witnesses. Obtain written reports/analyses of evidence, injuries, issues, and financial evaluations from expert witnesses. Assist in preparing pretrial and trial motions (motions in limine, protective order, preclude evidence to be admitted at trial, etc.) or responses to same received from defense. Prepare mediation statements and mediation statistics (obtain costs and prepare overall summary of file, including specials, liens, lops, priors, pertinent information); update filing and organize file in preparation for conference. Prepare trial exhibits, demonstrative charts, blow-ups, etc. Prepare trial notebook. Prepare voir dire, jury instructions, and verdict forms. Prepare and serve subpoenas for trial upon witnesses and, under direction of attorney, communicate with witness regarding trial attendance/appearance at trial. Draft, review, and file pleadings, petitions, briefs, arguments, pleadings, and other documents applicable to obtaining approval of minor settlements, guardianships, and estates for attorneys litigation case load relevant to court actions. Research procedural, administrative, and case law. Conduct computer-assisted legal and factual research using online resources such as Westlaw, Lexis, etc. Investigate facts and law of cases to determine causes of action and to prepare cases. Gather and analyze research data, such as statutes, decisions, and legal articles, codes, and documents. Must have 3+ years' experience in personal injury litigation or liability insurance defense litigation.

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